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2 Thank You for Joining Us, The Webinar Will Begin Shortly. While you are waiting please check out the Upcoming Webinars on

3 Before we begin just a few notes: During the presentation lines will be muted so only presenters can be heard. While you are listening please also put your phone on mute Do NOT put your phone on hold please hang up and call back If having trouble viewing the presentation please close out and log in using a different browser If your slides are not moving please refresh or log out & then log back in If you have any questions during the presentation, please feel free to enter them into the discussion box on the bottom left of your screen

4 WIPP is a national nonpartisan public policy organization, advocating on behalf of nearly 1 million women-owned businesses representing 61 business organizations. WIPP provides timely economic policy information and identifies important trends and opportunities to its membership.

5 Give Me 5 National program from WIPP & American Express OPEN designed to educate women business owners on how to apply for and secure federal procurement opportunities. Give Me 5 works to increase the representation of Women Business Owners that win government contracts. We provide accessible business education tools to assist both new and experienced federal contractors. Women Business Owners could gain more than $5 billion in annual revenues if the 5% contracting goal set by Congress is reached.

6 Hope A. Lane, Partner Hope A. Lane, CPA, leads Aronson LLC s Government Contract Consulting Practice with over 20 years of broad-based experience in the government contracting arena. She earned her Bachelor of Science Degree in Accounting from the University of North Carolina at Charlotte and is responsible for assisting clients in all areas of government contract-related financial compliance and contract administration. With an exclusive focus on government contracting, Ms. Lane possesses in-depth understanding and intensive hands-on experience. She has served in financial management positions with several regional federal contractors and has extensive experience in the management of all accounting and finance functions. Hope is actively involved in the Professional Services Council, National Contract Management Association and Women Impacting Public Policy. Ms. Lane is a guest speaker and lecturer for associations and industry trade groups and a featured speaker on the Government Contracting industry at Aronson LLC s Executive Briefings All Rights Reserved Aronson LLC Slide: 6

7 Give Me 5 144: Attributes of an Acceptable Accounting System October 31, All Rights Reserved 805 King Farm Boulevard Suite 300 Rockville, Maryland P F

8 About Aronson LLC Founded in Professionals located in Rockville, MD One of the largest CPA firms in the DC Metro Area 80 multi-disciplined Professionals dedicated to supporting Government Contractors Financial and Contract Compliance GSA schedules Audit, Assurance & Tax Software Systems and Outsourcing News and Trends for Today s Savvy Government Contractor 2012 All Rights Reserved Aronson LLC Slide: 8

9 Agenda Accounting System Application Accounting System Criteria DCAA Guidance Deficiency Process and Outcomes 2012 All Rights Reserved Aronson LLC Slide: 9

10 Definition DFARS clause Definition: Accounting system The system or systems of methods, procedures, and controls established to gather, record, classify, analyze, summarize, interpret, and present accurate and timely financial data 2012 All Rights Reserved Aronson LLC Slide: 10

11 Definition Definition: acceptable accounting system must provide reasonable assurance that: Applicable laws and regulations are complied with The accounting system and cost data are reliable Risk of misallocations and mischarges are minimized, and Contract allocations and charges are consistent with billing procedures 2012 All Rights Reserved Aronson LLC Slide: 11

12 Significant Deficiency Definition: Significant Deficiency A shortcoming in the (accounting) system that materially affects the ability of officials of the DoD to rely upon information produced by the system that is needed for management purposes 2012 All Rights Reserved Aronson LLC Slide: 12

13 Criteria Structure 1. Sound internal control environment, accounting framework, and organizational structure Segregation of duties Custody Authorization Record keeping 2012 All Rights Reserved Aronson LLC Slide: 13

14 Criteria Segregation 2. Proper segregation of direct from indirect costs Definition of Direct Costs Definition of Indirect Costs Chart of Accounts Job number functionality Limit job number population on timesheets Direct Indirect 2012 All Rights Reserved Aronson LLC Slide: 14

15 Criteria Direct Costs 3. Identification and accumulation of direct costs by contract Job number functionality Labor Travel and Meals Other Direct Costs Subcontractors and Consultants 2012 All Rights Reserved Aronson LLC Slide: 15

16 Criteria Indirect Costs 4. Logical and consistent method for the accumulation and allocation of indirect costs to intermediate and final cost objectives Reasonable tier structure Costs on the Trial Balance should be grouped into homogeneous groupings Consistent application of rates Budget and estimating Billing Forward pricing 2012 All Rights Reserved Aronson LLC Slide: 16

17 Criteria Accumulation 5. Accumulation of costs under general ledger (GL) control Job cost ledgers are reconcilable to the GL Fixed Assets QuickBooks does not have sub-ledgers 2012 All Rights Reserved Aronson LLC Slide: 17

18 Criteria Subsidiary Ledgers 6. Reconciliation of subsidiary cost ledgers and cost objectives to the general ledger Contract revenue summary Fixed Assets and accumulated depreciation Accrued payroll Billing Unbilled 2012 All Rights Reserved Aronson LLC Slide: 18

19 Criteria Adjustments 7. Approval and documentation of adjusting entries Payroll accruals Subcontractor / vendor expenses Month-end and year-end checklists 2012 All Rights Reserved Aronson LLC Slide: 19

20 Criteria Mgmt Review 8. Mgmt. reviews and/or conducts internal audits to ensure compliance with P&P s Based on size and complexity Small businesses may not have a separate internal audit function Quarterly / annual procedures 2012 All Rights Reserved Aronson LLC Slide: 20

21 Criteria - Timekeeping 9. Timekeeping system that identifies employees labor by intermediate or final cost objective Time recorded by all employees Standard timesheet with signatures and approvals recorded on a timely basis Overtime, Danger Pay, Post-differentials, etc All Rights Reserved Aronson LLC Slide: 21

22 Criteria Labor Distribution 10.Labor distribution system that charges direct and indirect labor to the appropriate cost objective Labor records reconcile to payroll records Quarterly 941s Annual W-2s Labor accruals are made and reversed monthly 2012 All Rights Reserved Aronson LLC Slide: 22

23 Criteria Posting 11.Interim determination of costs charged to a contract through posting of books of account Timekeeping, if external to the accounting system Bank reconciliations 2012 All Rights Reserved Aronson LLC Slide: 23

24 Criteria Unallowable Costs 12.Exclusion of unallowable costs based on FAR Part 31, and other contract provisions Training of employees and specifically accounting staff Recent DCAA focus Executive compensation Bonuses Trade shows / Conferences Automobile expenses for executives Periodic review by management 2012 All Rights Reserved Aronson LLC Slide: 24

25 Criteria Cost Level 13.Identification of costs by CLIN, ACRN, or other unit as defined by the contract Appropriate job number use Job ledger detail Detail shown on employee timesheets 2012 All Rights Reserved Aronson LLC Slide: 25

26 Criteria Pre/Post Production Costs 14.Segregation of preproduction from production costs Primarily for manufacturing companies Costs segregated Note: Most costs for manufacturers are direct, and the company would have a single rate structure (G&A) 2012 All Rights Reserved Aronson LLC Slide: 26

27 Criteria Contract Value 15.Cost accounting information related to: a. Contract and funding values and limits Contract briefs (ICS Schedule S) Cumulative amounts illustrated on billings PM and Mgmt. review on a periodic basis At-risk review and approval Value Funding Period of Performance FAR Limitation of Funds Costs will exceed 75% within the next 60 days 2012 All Rights Reserved Aronson LLC Slide: 27

28 Criteria Indirect Rates b. Indirect rate calculations Readily calculated from, or based on information from, the accounting system Calculated on a regular basis (monthly/quarterly) Reasonable structure in compliance with FAR Costs allocated over reasonable bases Labor Hours Labor Dollars Square Feet Monitor actual vs. provisional rates monthly/ quarterly 2012 All Rights Reserved Aronson LLC Slide: 28

29 Criteria Billings 16.Billings that can be reconciled for both current and cumulative amounts claimed All projects billed on a timely basis; not less than monthly Formalized billing checklist Appropriate information for each contract type T&M and CP labor hours, CLIN, cumulative billing, withholds, etc. FP percentage of completion, withholds, etc All Rights Reserved Aronson LLC Slide: 29

30 Criteria SubK Costs Process for the payment of subcontractor and vendor costs Accrual of invoices not yet received Timely payment of subcontractors and vendors in accordance with subcontractor agreements or vendor purchase orders Coding to appropriate projects 2012 All Rights Reserved Aronson LLC Slide: 30

31 Criteria Follow-on Pricing 17.Adequate data for use in pricing follow-on acquisitions Job cost reports provide relevant information Costs tracked from a business perspective to allow management to understand future work opportunities 2012 All Rights Reserved Aronson LLC Slide: 31

32 Criteria GAAP/CAS 18.Accounting practices in accordance with GAAP and CAS, if applicable Accrual vs. cash accounting Independent audit, review, or compilation CAS-covered CAS 401, 402, 405, 406 apply to all contractors 2012 All Rights Reserved Aronson LLC Slide: 32

33 Policies & Procedures to be Compliant Direct vs. Indirect Costs Allocation of Indirect Expenses Unallowable Costs Time & Expense Reporting Billing Compensation and Bonus Budget and Planning Travel and Expense Reporting Estimating Code of Conduct and Business Ethics 2012 All Rights Reserved Aronson LLC Slide: 33

34 Policies & Procedures Cont d AP Disbursements Non-Purchase Order AP Vouchers Vendor Maintenance Voiding AP Checks Billing CP and T&M Billing FP Cash Receipts Contract Modifications Set-Up New Customers Set-Up New Projects Payroll Processing Timesheet and Labor Processing 2012 All Rights Reserved Aronson LLC Slide: 34

35 DCAA Guidance - MRD 12-PPS-009(R) Internal Control Audit Planning Summary (ICAPS) procedures consolidated Changes the focus of existing audit guidance and the business system they pertain to Accounting System will now include Labor Accounting System and Indirect and ODC. Billing, Control Environment and IT General System Control subsystems performed separately 2012 All Rights Reserved Aronson LLC Slide: 35

36 DCAA Guidance - MRD 12-PPS-009(R) Other ICAPS Estimating System includes Budget and Planning Compensation System will now be included in forward pricing and incurred cost audits 2012 All Rights Reserved Aronson LLC Slide: 36

37 Points of Contact Hope A. Lane (301) Connect with me on 2012 All Rights Reserved Aronson LLC Slide: 37

38 Questions???

39 Thank You For Participating Following this call you will receive links to the podcast of this session, along with a brief survey. Your feedback is important to us! Please take a moment to fill out the survey so that we can bring you the best training possible.

40 WIPP Members: Procurement Committee Meeting Tomorrow at 2pm ET As we head into the 2012 Election, join us for an update and conversation on the status of potential Sequestration and where we stand with the FY 2013 National Defense Authorization Act. We will also be providing a summary of our October 24 th WOSB Opportunity Forum with the Department of Defense, and asking you for your feedback as we plan more WOSB Forums in 2013.

41 Get Involved! Join a policy issue committee and learn how policy can impact your business growth Make your voice heard - become a member of our national Instant Impact Advocacy Team Participate in our educational series unlimited opportunities for you and your staff Receive weekly policy updates and briefings WIPP Questions? Contact WIPP Staff Program & Education Coordinator: Michael Fravel (415) Membership Coordinator: Hannah Starkel (415)

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